Title
Comglasco Corp. vs. Santos Car Check Center Corp.
Case
G.R. No. 202989
Decision Date
Mar 25, 2015
Santos leased a property to Comglasco for five years; Comglasco pre-terminated, refused to pay rent, and was sued. Courts ruled in Santos' favor, affirming breach of contract and awarding damages, with reduced attorney’s fees.
A

Case Digest (G.R. No. 202989)

Facts:

  • Lease Agreement
    • On August 16, 2000, Santos Car Check Center Corporation (Santos), owner of a showroom at 75 Delgado Street, Iloilo City, leased the space to Comglasco Corporation (Comglasco) for five years.
    • Rental schedule: ₱60,000/month (1st year), ₱66,000/month (2nd year), ₱72,600/month (3rd–5th years).
  • Pre-termination and Default
    • On October 4, 2001, Comglasco sent a letter notifying Santos of its intention to pre-terminate the lease effective December 1, 2001. Santos refused, insisting on the five-year term.
    • Comglasco vacated the premises on January 15, 2002, ceased paying rent, and ignored multiple demand letters, including a final demand on September 15, 2003.
  • Trial and Appeals
    • Santos filed suit for breach of contract on October 20, 2003; summons served January 21, 2004. Comglasco’s motion to dismiss for improper service was denied; it filed its Answer on June 28, 2004.
    • Santos moved for judgment on the pleadings under Rule 34, §1; the RTC granted it and, on August 18, 2004, ordered Comglasco to pay unpaid rentals (Jan 16, 2002–Aug 15, 2003) totaling ₱1,333,200 plus 12% interest, plus ₱200,000 attorney’s fees, ₱50,000 litigation expenses, ₱400,000 exemplary damages, and costs.
    • The Court of Appeals (CA), in a Decision dated August 10, 2011, affirmed the RTC’s decision but reduced attorney’s fees to ₱100,000 and deleted litigation expenses and exemplary damages.
    • Comglasco petitioned the Supreme Court raising issues on judgment on the pleadings, material issues in its Answer, summary judgment vs. judgment on pleadings, credit for advance rental/deposit, and basis for attorney’s fees.

Issues:

  • Whether judgment on the pleadings was properly invoked by the trial court.
  • Whether Comglasco’s Answer raised material issues requiring evidence.
  • Whether summary judgment rather than judgment on the pleadings was the proper remedy.
  • Whether Comglasco’s advance rental and deposit (₱309,000) should be credited against Santos’s award.
  • Whether attorney’s fees may be granted without proof and legal stipulation.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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